Board notes: 5 September 2019

The Chair welcomed everyone and thanked them for coming. It was noted that the Chief Executive was on leave. Whilst unable to attend, he had been fully briefed.

The Chair began the meeting by setting out the governance procedures under which the meeting had been called. He clarified that it had been called under the urgency procedure, meaning the Commissioners were being consulted by the acting Accounting Officer on the action to be taken, and this would then be reported at the September Commission Board. At that time the Board would be asked to endorse formally any decisions taken, and consider whether further action was required.

The Chair advised that the Commission was faced with the possibility of an early United Kingdom Parliamentary General Election (UKPGE) and it was necessary to ensure that the Commission was prepared and had the funding to fulfil its obligations in the event of an UKPGE being announced.

The Commissioners heard from each of the members of the Executive Team, who provided details on the readiness of their teams and the contingency arrangements that were already in place ahead of any announcement. Normal contingency planning for a UKPGE meant that plans had already been reviewed and updated regularly and had ensured that we were confident, though not complacent, in our preparedness. Guidance had already been prepared for electoral administrators, political parties and campaigners and was either available now, or ready to be finalised and published as soon as the date of any poll was confirmed.

In response to a question, the Director of Electoral Administration and Guidance advised that while there would undoubtedly be challenges, there were no specific concerns about the ability of local authorities to deliver a UKPGE in October. She added that it was intended to make use of the Electoral Coordination and Advisory Board (ECAB) and the network of Regional Returning Officers, even though they had no formal role in a UKPGE. The Director of Regulation confirmed that our state of readiness on the regulatory side was also good. She noted that should a UKPGE be called with only six weeks’ notice or less, there would be no time to register new political parties. 

Commissioners were assured by the Director of Regulation routine monitoring of campaign activity continued, and we continued to proactively work with parties to promote compliance. We continued to engage with the Cabinet Office and security agencies as appropriate. 

A Commissioner asked whether the Commission had provided a response to the public consultation on a draft Code of Practice on the use of personal data in political campaigning, recently published by the Information Commissioners Office (ICO). The Director of Communications, Policy and Research advised that we were planning to respond.

Action: The Director of Communications, Policy and Research to circulate to Commissioners after the meeting a link to the ICO’s consultation on a draft Code of Practice.

The Director for Communications, Policy and Research advised that the approach to the voter registration campaign would be similar to that used for the recent EPE, which had been proven to be successful. Television advertising would be supplemented by digital advertising targeting the known under-registered groups. The maximum budget for the campaign itself would be just over £1.4 million, comparable to the spending in 2017, though the actual amount would depend upon the campaign period. As usual there would be a lot of work with partners, including working through government agencies. Plans to integrate our Your Vote Matters website with the new corporate website would continue but contingency plans were in place should there be any unforeseen issues.

Assurances were given by the Executive Team that additional staffing resources required had been identified, including staff to handle additional demand from public enquiries, complaints and Freedom of Information (FOI) requests, as well as from parties and campaigners.

The Director for Finance and Corporate Services advised the Commissioners that, following discussions with the Clerk to the Speaker’s Committee, there would be insufficient parliamentary time to access the additional funding required to deliver a UKPGE in October through a Supplementary Estimate. The alternative was to use the Contingency Fund process run by the HM Treasury. This would be initiated once a UKPGE was inevitable and a statement had been provided to the House of Commons. There would then need to be a Supplementary Estimate through the Speaker’s Committee in due course.

The Commissioners were advised that the budget requirement to deliver a UKPGE was approximately £2.4 - £2.5m in 2019/20, which was broadly comparable to the budget required for the previous poll in 2017. Provision for legal costs had not been included but it was confirmed that there was a small contingency in the 2019/20 budget and costs were more likely to be incurred in the 2020/21 financial year. There would also be a need for a new Corporate Plan after any election, and there would need to be a discussion about how ambitious we should be with the development of the plan if there were little time to prepare it.

A Commissioner asked that the public awareness and external communications budget figure be broken down to reflect the campaign spend and the separate spend on additional communications activity. Another Commissioner requested greater assurance that our own registration campaign spend offered good value for public money. The Director of Communications, Policy and Research provided reassurances for the current proposed campaign but noted that it would be possible to look at this in greater detail for future electoral events.

Action: A deep dive session on the public value of campaign spend to be scheduled for a future Commission Board.

Elan Closs Stephens left the meeting at 3.00pm.

It was agreed that, following this consultation with Commissioners, the acting Accounting Officer, the Director for Finance and Corporate Services, would initiate the Contingency Funding process should a UKPGE be announced prior to the September Commission Board meeting. If this action were taken it would be formally reported at that Commission Board meeting.

Action: Report to the next Commission Board the note of this meeting of Electoral Commissioners.

The meeting finished at 3.10pm.